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PRIVACY & COOKIE POLICY

Last updated: 13th June 2024

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INTRODUCTION

AlphaSights Ltd, its subsidiaries and affiliates (“AlphaSights”, “we”, “us”,
“our”) respect your privacy and are committed to protecting your personal data.
This Privacy & Cookie Policy (also referred to as Privacy Policy) describes our
data collection and processing activities, including:

 * what personal data we may collect when you, interact with us through our
   various channels online (such as our website at www.alphasights.com and via
   our platform, apps and social networks) and offline (such as over the
   telephone, via text, messaging application, in meetings or at events) and
   what we may do with that personal data;
 * how we may collect and process information through the use of cookies and
   related tracking technologies on our online channels; and
 * your data protection rights, including (where applicable) a right to object
   to processing and a right to withdraw your consent to processing, and how to
   exercise them.

When we refer to “personal data” in this Privacy Policy we are referring to any
information that falls under: (i) the definition of “personal data” under the
General Data Protection Regulation 2016/679 (“GDPR”) or other applicable data
privacy law, and (ii) the definition of “personal information” under the
California Consumer Privacy Act of 2018 (“CCPA”), the China Personal Information
Protection Law (“PIPL”) and any other applicable data privacy law.

More information about your rights and how to exercise them is set out in
Section 10 below. If you are a resident of California or the People’s Republic
of China, please also see Section 12 and 13 respectively.

It is important that you read this Privacy & Cookie Policy together with any
other privacy notice or fair processing notice we may provide on specific
occasions when we are collecting or processing personal data about you, so that
you are fully aware of how and why we are using your data. This Privacy & Cookie
Policy supplements the other notices and is not intended to override them.

To manage your cookies, please click here.

1. Important information and who we are


AlphaSights is responsible for the processing of your personal data as described
in this Privacy Policy. For the purposes of the GDPR, CCPA and the PIPL, in
respect of our core service offerings, AlphaSights acts as the controller,
business and personal information processor respectively of such personal data.

The contact details of AlphaSights Ltd and our Data Protection Officer are
provided in Section 11 below.

1.1. Updates to this privacy & cookie policy
This Privacy & Cookie Policy may be updated periodically. We will update the
date at the top of this Privacy & Cookie Policy accordingly and encourage you to
check for changes to this Privacy & Cookie Policy, which will be available on
our website. On some occasions, we may also actively advise you of specific data
handling activities or significant changes to this Privacy & Cookie Policy, as
required by applicable law.

1.2 Third-party links
Our website(s) may include links to or functionality from third-party websites,
plug-ins and applications. Clicking on those links or enabling those connections
may allow third parties to collect or share data about you. We do not control
these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy policy of every
website you visit.

1.3 AlphaSights as data processor
From time to time we may process personal data in the role of a processor or,
for the purposes of the CCPA, service provider, on behalf of our clients,
including where we facilitate the provision of specific output submitted by or
derived from experts or clients’ engagements with experts, in each case at our
clients’ sole request. In these specific circumstances, our clients act as the
controller and each have in place separate privacy and data security practices
which will also apply. AlphaSights will however, support our clients as
necessary to respond to any requests you have in respect of the processing of
your personal data. If you require any further information about our clients’
data processing activities please get in touch using the details in Section 11.

Please note that if you participate in a survey facilitated by AlphaSights, this
survey may either be programmed by AlphaSights on behalf of our client or
programmed by a third party directly on behalf of our client. This Privacy
Policy will apply to the processing of your survey responses where AlphaSights
is the programmer of the survey. Where AlphaSights does not programme the
survey, AlphaSights will not collect, store or otherwise process your survey
results and the third party survey programmer and/or our client will have in
place separate privacy and data security practices which will apply.

2. What personal data do we collect and how?


"Personal data" means any personally identifiable information belonging to an
identifiable natural person, including but not limited to, an identifier such as
a name, an identification number, location data, an online identifier or factors
specific to the physical, economic, cultural or social identity of that natural
person, and for the avoidance of doubt includes the term "personal data" as
defined in the GDPR, "personally identifiable information" as defined in the
CCPA and "personal information" as defined in the PIPL.

2.1 Categories of personal data collected
We may collect, create, use, store and otherwise process different categories of
personal data depending on how you use and interact with our products, services
and online channels. We have grouped these categories below as follows:

 * Identifier Data, including first name, maiden name, last name, job title,
   company name and username and password.
 * Contact Data, including your address(es), email address(es) and telephone
   number(s).
 * Profile Data, including your CV, professional background, professional
   headshot, languages spoken, location and country of residence, relevant
   qualifications, career history and moves and any additional information,
   which may include special category personal data and sensitive personal
   information to the extent it is manifestly made public by you or you
   voluntarily choose to provide it to AlphaSights in connection with a
   particular project or service offering. See Section 4 below for the
   additional measures we have put in place when processing these special
   categories of personal data.
 * Due Diligence Data, including data you make publicly available (e.g. via
   social media and networking platforms) where required to meet specific anti
   money laundering, counter terrorism financing and anti-bribery legislation or
   other regulatory requirements or where needed to research, filter and verify
   experts or to screen for potential conflicts of interest.
 * Identity Data (only if, in applicable jurisdictions, you have consented to an
   identity verification check as an AlphaSights expert), including a copy of
   your governmental ID and a photo of your face that contains facial scan or
   “biometric” data. For more information on whether this applies to you see
   Section 4.
 * Financial Data (if we need to pay you), including bank account details.
 * Payment Data (if you subscribe to our platform as a business user), including
   your card details and other information to process your payments, including
   your payment history and billing address.
 * Transaction Data, including interactions you may have had with us (e.g.
   parties entering and exiting our conference bridge, duration and time of
   interactions) and any expert/client feedback.
 * Marketing and Communications Data, including your preferences in receiving
   marketing from us and your communication preferences.
 * Technical Data, including internet protocol (IP) address, login data, browser
   type and version, time zone setting and location, browser plug-in types and
   versions, operating system and platform and other technology on the devices
   you use to access our website(s) and online services.
 * Usage Data, including information about how you use our website, social media
   pages, apps, products and services, including the URL clickstream to, through
   and from our online channels (including date and time), products you viewed
   or searched for, the content (and any ads) that you view or interact with,
   page response times, download errors, length of visits to certain pages, page
   interaction information (such as scrolling, clicks, and mouse-overs or
   acceptance of our Terms of Engagement), and methods used to browse away from
   the page.



2.2 Circumstances when we may collect your personal data
We may collect such categories of personal data either directly from you or from
third parties and publicly available sources. The table below sets out which
categories of personal data are collected in which circumstances. From time to
time, we may ask you to confirm the accuracy of the personal data we process
about you.

Circumstance Categories of Personal Data (i) Where you interact with us directly
If you are employed by a client of AlphaSights and your information has been
shared with us for the purposes of you using our products and services
Identifier Data and Contact Data If you use and interact with our products,
services and online channels including our website Technical Data and Usage Data
If you communicate with us by post, phone, email, surveys or otherwise
Identifier Data, Contact Data, Profile Data, Transaction Data and Marketing and
Communications Data If you voluntarily submit certain information to us, for
example during a call with our employees, by filling out a survey or by
uploading information to our platform or one of our approved third party
providers Information you have provided as part of that request including
Identifier Data, Contact Data, Profile Data, Identity Data and Financial Data.
If you sign up to an event or webinar Identifier Data, Contact Data and Profile
Data If you request to be paid by AlphaSights or receive other monetary or
non-monetary compensation from AlphaSights Contact Data and Financial Data If
you express an interest in obtaining additional information about our products,
services or employment opportunities, or otherwise use our "Contact Us" page or
similar features Identifier Data, Contact Data, Profile Data and Marketing and
Communications Data If you are a supplier, contractor or service provider to
AlphaSights (or work for a supplier or service provider) Identifier Data,
Contact Data and Financial Data If you subscribe to our platform as an
individual business user in your capacity as a representative of your employer.
Identifier Data, Contact Data, Payment Data, Technical Data and Usage Data (ii)
Where we collect information about you from other sources If we identify you as
a potentially relevant expert for a specific client project Identifier Data,
Contact Data, Profile Data and Due Diligence Data If we need to conduct any
vetting or verification processes in order to contract with you Due Diligence
Data If you interact with our products and services Technical Data from
analytics, technology and hosting providers

2.3 Aggregating your personal data
We aggregate your Usage Data with the information of other website visitors,
experts and clients, creating a dataset of information about the usage of our
online channels, our apps, products and services, and other general, grouped
information about our user base. It provides a valuable insight into the use of
our services and we may share it with select third parties. This dataset is
aggregated and anonymised, meaning it cannot directly identify you as an
individual and is not considered personal data.

2.4 When am I required to provide personal data?
We may have a legal obligation to collect and process your personal data, or we
may require your personal data in order to provide you with specific products
and services, including accessing our platform.

If you fail to provide that data when requested, we may not be able to perform
the contract we have or are trying to enter into with you and/or the quality of
the products and services we provide to you might be affected. In these
circumstances, we may cancel a service you receive from us or stop proceeding
with a contract we are trying to enter into with you, but we will notify you if
this is the case at the time.

Please note that this does not apply to the collection of biometric data
provided by experts in applicable jurisdictions for identity verification
purposes. The provision of biometric data is voluntary and will not in any way
impact our payment obligations to you. However, we may be unable to engage you
in any further engagements with AlphaSights without first completing our
identity check.

3. Why we process your personal data and the lawful bases on which we rely


In accordance with the GDPR, we rely on a number of lawful bases to process your
personal data (including, where legally permissible, special categories of
personal data). Where we process your personal information in the PRC, please
see Section 13 for the legal bases we rely on to process your personal data in
accordance with the PIPL.

Where we rely on legitimate interests (and it is legally permissible to do so)
we have carried out a balancing test to ensure:

 1. The processing is lawful, proportionate and conducted in accordance with the
    terms of this Privacy Policy;
 2. We have a legitimate business need to perform the processing;
 3. There is no material likelihood of any adverse impact on your interests,
    fundamental rights, or freedoms, as a result of the processing.

You can obtain information on any of our balancing tests by contacting us using
the details in Section 11 below.

We may collect and process your personal data for the following purposes and,
where legally permissible, rely on the following lawful bases:

 * Where we need to perform a contract we are about to enter into or have
   entered into with you. This includes:
   * Performing our contract with you for the provision of our products and
     services and sending you service-related communications;
   * Facilitating expert engagements in respect of which you have agreed to
     participate or facilitating the creation of other output;
   * Managing our client and user accounts, such as billing, subscription
     management, providing client support and client relationship management;
   * Determining compensation for AlphaSights employees such as commission, by
     processing your Transaction Data;
   * Managing payments to the extent the processing of Financial Data is
     necessary to compensate our experts or pay our suppliers;

 * Where it is necessary for our legitimate interests and we have assessed that
   your interests, rights and freedoms do not override those interests:
   * It is necessary for our legitimate interest in facilitating appropriate and
     legally compliant engagements between experts and our clients to process
     your personal data in order to:
     * research, filter, verify and monitor experts and to screen for potential
       conflicts of interest in order to assess and recommend an expert’s
       appropriateness for a particular client engagement and to meet applicable
       legal, regulatory and compliance requirements, including conducting
       proportionate searches relating to bankruptcy, political affiliation and
       criminal convictions;
     * conduct identity verification and other fraud detection activities.
   * It is necessary for our legitimate interest in providing online and offline
     content (including improving the user experience) to our clients,
     prospective clients, experts and other interested parties to process your
     personal data in order to:
     * monitor, maintain, develop and improve the performance of our sites,
       products and services and customer relationships;
     * analyse trends, usage and activities in connection with our products and
       services, and optimise our marketing efforts and measure the
       effectiveness of our advertising campaigns and to grow and inform our
       marketing strategy;
     * manage our own internal functions such as keeping our sites secure,
       (including troubleshooting, data analysis, testing, system maintenance,
       support, reporting and hosting of data), management and corporate
       reporting, internal research and analytics and to improve business
       efficacies;
     * create aggregate and statistical data (which cannot be used to identify
       you). For example, aggregate data may include data that describes the
       general demographics, usage or other characteristics of our site’s users.
   * It is necessary for our legitimate interest in complying with all legal,
     regulatory and compliance requirements to process your personal data in
     order to:
     * enforce compliance with our policies and procedures;
     * manage and provide all necessary assistance in respect of any legal
       claims or other compliance, regulatory, auditing, investigatory or
       disciplinary purposes (including disclosure of such information in
       connection with legal process or litigation).

 * When you have expressly consented to us processing your personal data. This
   includes, where required under applicable law:
   * where you ask us to send marketing information via certain mediums,
     including by email. For more information about how to modify your
     preferences about marketing communications, please see Section 10.1;
   * where we record phone calls between clients and experts at the request of
     clients for compliance purposes;
   * where we place non-essential cookies or similar technologies on your
     device;
   * where, on other occasions we ask for your consent, for the purpose we
     explain at the time.

Where consent is relied on, you have the right to withdraw it at any time by
contacting us. See Section 11 for our contact details.

 * Where we need to comply with a legal or regulatory obligation. This includes:
   * in response to requests by government or law enforcement authorities
     conducting an investigation;
   * to comply with applicable reporting or other legal obligations.

Your personal data may be combined from the different sources identified in
Section 2 for the purposes outlined above.

We do not conduct any automated decision-making using your personal data.

4. Special category data


In certain limited situations we may need to process, or ask third parties to
process on our behalf, your special category personal data. Special category
personal data means information that can reveal your racial or ethnic origin,
political opinions, religious or philosophical beliefs, trade union membership
as well as genetic or biometric data (if used to uniquely identify that person)
and information concerning a person’s health, sex life, or sexual orientation.

Where we need to process special category data, data protection laws require us
to meet one of the specific conditions in Article 9 of the GDPR. This includes
where your personal data is manifestly made public by you, e.g. on the internet.
We will also rely on your prior, explicit consent to process:

 * Profile Data that you voluntarily share with us that falls within the
   definition of special category personal data, including personal data
   revealing your racial or ethnic origin and data concerning your health or
   sexual orientation, for the purposes of facilitating specific projects that
   fall within that scope;
 * any facial scan data that is processed by an approved third party on our
   behalf to verify your identity.

Your consent is entirely voluntary and failure to provide consent will not
prevent us from fulfilling our contractual obligations to you.

5. Cookies and related technologies


We may be required to share your personal data with the third parties listed
below for the purposes described in Section 3 above or otherwise with your
consent:

Affiliates: AlphaSights is a global business, headquartered in the UK. The
personal data collected by us in accordance with this Privacy & Cookie Policy
may be used and shared amongst our group companies (acting on behalf of
AlphaSights Ltd) to support the effective functioning of the AlphaSights Group
business and the provision of its products and services.

Service Providers: When we employ a third-party to perform a function on our
behalf, for example to provide software and services that support the operation
and delivery of AlphaSights’ business and its products and services, we provide
it with the personal data that it needs to perform its specific function. These
companies are contractually authorised to use your personal data only as
necessary to provide these products or services to us. We may use service
providers for various purposes, including:

 * delivering our products and services;
 * IT, hosting and data security;
 * payments, billing and support services, including the facilitation of
   compensation (both monetary and non-monetary) to experts;
 * business development, marketing and communications.

We may also share personal data where necessary with our accountants, auditors,
lawyers and other outside professional advisors to AlphaSights, subject to
binding contractual obligations of confidentiality.

Clients: We may share Identifier Data, Contact Data, Due Diligence Data, Profile
Data and Transaction Data relating to experts with our clients in connection
with a particular project as further described in our Compliance Due Diligence
Packs, Access Terms and Terms of Engagement.

Experts: We may share Identifier Data relating to our clients with our experts
in connection with a particular project as further described in our Compliance
Due Diligence Packs and Access Terms.

Legal Requirements: We disclose personal data to government authorities,
regulators or other third-parties if required to do so by law or in the good
faith belief that such action is necessary to (a) comply with a subpoena, court
order or similar legal obligation; (b) protect and defend our rights or
property; (c) act in urgent circumstances to protect the personal safety of
users of any website or the public; (d) protect against legal liability; (e)
investigate fraud or other unlawful activity; or (f) as otherwise required or
permitted by law.

Business Transfers: As we develop our business, we might sell or buy businesses
or assets. In the event of a corporate sale, merger, reorganisation, dissolution
or similar event, including in bankruptcy, your personal data may be part of the
transferred assets. You will be notified via email and/or a prominent notice on
our website of any change in ownership or uses of your personal data, as well as
any choices you may have regarding your personal data.

Third-Party Partners: With your consent, we may share your personal data
(obtained through the use of cookies) with selected third-party partners for the
purposes of servicing relevant adverts to you (see Section 5.1 above for more
information).

Artificial Intelligence ‘AI’ Technology Partners: AlphaSights may utilise AI
technology to provide you with certain services, including the integration of
GPT models into our platform to enhance user experience and functionality.
Should you decide to use such technologies, any personal data provided by you
(including, but not limited to, search queries) will be shared with the
underlying third party AI provider for the purposes of performing its specific
function and be processed in accordance with its terms.

6. Who do we share your personal data with?


We may be required to share your personal data with the third parties listed
below for the purposes described in Section 3 above or otherwise with your
consent:

Affiliates: AlphaSights is a global business, headquartered in the UK. The
personal data collected by us in accordance with this Privacy & Cookie Policy
may be used and shared amongst our group companies (acting on behalf of
AlphaSights Ltd) to support the effective functioning of the AlphaSights Group
business and the provision of its products and services.

Service Providers: When we employ a third-party to perform a function on our
behalf, for example to provide software and services that support the operation
and delivery of AlphaSights’ business and its products and services, we provide
it with the personal data that it needs to perform its specific function. These
companies are contractually authorised to use your personal data only as
necessary to provide these products or services to us. We may use service
providers for various purposes, including:

 * delivering our products and services;
 * IT, hosting and data security;
 * payments, billing and support services, including the facilitation of
   compensation (both monetary and non-monetary) to experts;
 * business development, marketing and communications.

We may also share personal data where necessary with our accountants, auditors,
lawyers and other outside professional advisors to AlphaSights, subject to
binding contractual obligations of confidentiality.

Clients: We may share Identifier Data, Contact Data, Due Diligence Data, Profile
Data and Transaction Data relating to experts with our clients in connection
with a particular project as further described in our Compliance Due Diligence
Packs, Access Terms and Terms of Engagement.

Experts: We may share Identifier Data relating to our clients with our experts
in connection with a particular project as further described in our Compliance
Due Diligence Packs and Access Terms.

Legal Requirements: We disclose personal data to government authorities,
regulators or other third-parties if required to do so by law or in the good
faith belief that such action is necessary to (a) comply with a subpoena, court
order or similar legal obligation; (b) protect and defend our rights or
property; (c) act in urgent circumstances to protect the personal safety of
users of any website or the public; (d) protect against legal liability; (e)
investigate fraud or other unlawful activity; or (f) as otherwise required or
permitted by law.

Business Transfers: As we develop our business, we might sell or buy businesses
or assets. In the event of a corporate sale, merger, reorganisation, dissolution
or similar event, including in bankruptcy, your personal data may be part of the
transferred assets. You will be notified via email and/or a prominent notice on
our website of any change in ownership or uses of your personal data, as well as
any choices you may have regarding your personal data.

Third-Party Partners: With your consent, we may share your personal data
(obtained through the use of cookies) with selected third-party partners for the
purposes of servicing relevant adverts to you (see Section 5.1 above for more
information).

Artificial Intelligence ‘AI’ Technology Partners: AlphaSights may utilise AI
technology to provide you with certain services, including the integration of
GPT models into our platform to enhance user experience and functionality.
Should you decide to use such technologies, any personal data provided by you
(including, but not limited to, search queries) will be shared with the
underlying third party AI provider for the purposes of performing its specific
function and be processed in accordance with its terms.

7. International transfers of personal data


Your personal data may be transferred to and stored by AlphaSights in the US. It
may also be used and accessed by members of our group including in the US, Hong
Kong, the United Arab Emirates, China, Japan and South Korea and transferred to
the third parties disclosed in Section 6 above who are internationally based.
Accordingly, your personal data may be processed outside of your country or
jurisdiction, including in locations that are not subject to an adequacy
decision by the European Commission or the UK ICO.

If we transfer your personal data outside of the UK or the EEA (within our Group
or to third parties), we ensure that the recipient of your personal data has
appropriate safeguards in place to protect your personal data. These are that:

 * there is a decision by the European Commission or other applicable data
   protection legislator or regulator, that the country to which the data is
   transferred provides an adequate level of data protection;
 * in absence of such decision, our contracts with the relevant third parties
   include approved standard contractual data protection clauses or
   international data transfer agreements approved by the European Commission
   and the UK Information Commissioner’s Office; or
 * there is an alternative mechanism for the transfer of data as approved by the
   European Commission (Art. 46 GDPR) or other applicable regulator or
   legislator.

8. Data security


We have put in place appropriate organisational, technical and physical security
measures to prevent your personal data from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other
third parties who have a business need to know. They should only process your
personal data on our instructions and are subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected personal data
breach and will notify you and any applicable regulator of a breach where we are
legally required to do so.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal data,
we cannot guarantee the security of your personal data transmitted to our
website; any transmission is at your own risk. You are also responsible for
protecting your password, limiting access to your devices and signing out of our
online channels after your sessions.

9. How long will you use my personal data for?


We will only retain your personal data for as long as we believe necessary to
fulfil the purposes we collected it for (see Section 3 above), including for the
purposes of satisfying any legal, accounting, reporting or audit requirements.
To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm
from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are
available by contacting us using the details in Section 11 below. Any Identity
Data processed on AlphaSights’ behalf by our third party provider for the
purposes of identity verification checks will be automatically deleted no later
than 50 days after collection.

10. Your legal rights relating to your personal data


10.1 Your rights
Under certain circumstances, you have rights under data protection laws in
relation to your personal data. These include the right:

To request access to your personal data (commonly known as a "subject access
request"). This enables you to receive a copy of the personal data we hold about
you and to check that we are lawfully processing it.

To request correction of the personal data that we hold about you. This enables
you to have any incomplete or inaccurate data we hold about you corrected,
although we may need to verify the accuracy of the new data you provide to us.

To request erasure of your personal data. This enables you to ask us to delete
or remove personal data where there is no good reason for us to continue
processing it. You also have the right to ask us to delete or remove your
personal data where you have successfully exercised your right to object to
processing (see below), or where we may have processed your information
unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be notified to you, if
applicable, at the time of your request.

To object to processing of your personal data. This is where we are relying on a
legitimate interest to process your personal data and there is something about
your particular situation that makes you want to object to that processing. In
some cases, we may demonstrate that we have compelling legitimate grounds to
process your personal data that override your objection.

To opt out of direct marketing. You have an absolute right to opt out of direct
marketing or profiling we carry out for direct marketing at any time. You can do
this by following the instructions in the communication or by contacting us
using the details in Section 11 below. Please note that opting out of marketing
communications does not opt you out of receiving important business
communications related to your current relationship with us, such as
communications about your account.

To request restriction of processing of your personal data. This enables you to
ask us to suspend the processing of your personal data in the following
scenarios: (a) if you want us to establish the data’s accuracy; (b) where our
use of the data is unlawful but you do not want us to erase it; (c) where you
need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to our use
of your data but we need to verify whether we have overriding legitimate grounds
to use it.

To request the transfer of your personal data to you or to a third party. We
will provide to you, or a third party you have chosen, with your personal data
in a structured, commonly used, machine-readable format. Note that this right
only applies to electronically held information which you originally provided to
AlphaSights.

To withdraw consent. This occurs at any time where we are relying on consent to
process your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We
will advise you if this is the case at the time you withdraw your consent.

All these rights may be limited by relevant exemptions under applicable data
privacy laws. We will inform you of any relevant exemptions we rely upon when
responding to any request you make.

10.2 How to exercise your rights
To exercise your rights, please contact us using the information in Section 11
below. Your personal data may be processed in order for us to respond to your
request.

10.3 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any
of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we can refuse to
comply with your request in these circumstances.

10.4 What we may need from you
We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights). This is a security measure to ensure that personal data
is not disclosed to someone who doesn’t have the right to receive it. We may
also contact you to ask you for further information in relation to your request
to speed up our response.

10.5 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it
may take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated.

11. How do you get in touch with us?


We hope we can satisfy any queries you may have about the way we process your
personal data. If you have any concerns or would like to exercise any of your
rights, please use this form available on our website, contact our Data
Protection Officer by email at dpo@alphasights.com or write to us at AlphaSights
Ltd, Thames Court, 1 Queenhithe, London, EC4V 3DX, United Kingdom. To find the
details of your local AlphaSights office please click here. If you are a
California resident, you may also contact us at +1 (888) 369-1693 regarding your
rights under the California Consumer Privacy Act.

We are committed to working with you to obtain a fair resolution of any
complaint or concern about your privacy. If you have any unresolved concerns,
you have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection
issues (www.ico.org.uk), or to your local data protection authority.

12. Your rights as a California resident


If you are a California resident, you have specific rights in respect of the
processing of your personal information under the California Consumer Privacy
Act (as amended by the California Privacy Rights Act). See Section 11 about how
to contact us to exercise any of these rights:

12.1 Right to know
You have a right to be informed of the categories of personal information listed
in the CCPA that AlphaSights may collect about you. These include:

 1.  Identifiers, including name, address, IP address, email address and
     driver’s licence number (to the extent you voluntarily choose to provide it
     in connection with an identity verification check);
 2.  Personal information categories in the California Customer Records statute,
     including name, signature, address, telephone number, driver’s licence (to
     the extent you voluntarily choose to provide it in connection with an
     identity verification check), education, employment history, bank account
     number (to the extent required to process payment) and medical information
     (to the extent voluntarily provided in connection with a specific project);
 3.  Characteristics of protected classifications under California or federal
     law to the extent you voluntarily choose to provide it to AlphaSights in
     connection with a particular project or service offering;
 4.  Commercial information, including records of products or services purchased
     or other purchasing histories or tendencies;
 5.  Biometric information to the extent you voluntarily choose to provide it in
     connection with an identity verification check;
 6.  Internet or other electronic network activity information, including, but
     not limited to, browsing history, search history and information regarding
     a consumer’s interaction with an internet website or advertisement;
 7.  Geolocation data;
 8.  Audio information in the form of telephone recordings requested by clients
     for compliance purposes to the extent you voluntarily consent to being
     recorded;
 9.  Professional or employment-related information;
 10. Inferences drawn from personal information to create a profile about a
     consumer reflecting their preferences, attitudes, abilities and aptitudes;
 11. Sensitive personal information, to the extent you voluntarily consent to
     providing it or otherwise make it manifestly public, including:
     1. For the purposes of identity verification checks only, your driver’s
        licence or passport number and biometric facial scan data;
     2. For the purposes of a specific project or service offering only, your
        racial or ethnic origin, religious or philosophical beliefs or union
        membership, or personal information concerning your health or your
        sexual orientation;
     3. For the purposes of processing payment only, your financial information;
        and
     4. For the purposes of analysing user activity and ensuring compliance with
        specific legal and compliance requirements your precise geolocation.

Please see Section 2.1 above for more information on the specific types of
personal information we may collect about you.

Please see the following sections above for information on:

 * The sources from which this personal information is collected (Section 2.2);
 * The purposes for which these categories of personal information are used
   (Section 3);
 * The categories of third parties to whom the personal information is disclosed
   and the business or commercial purposes for doing so (Section 6);
 * The length of time AlphaSights intends to retain the personal information
   (Section 9).

You also have the right to receive a copy of the specific personal information
we hold about you. We may need to request specific information from you to help
us confirm your identity and ensure your right to access your personal
information.

12.2 Right to delete
You can request that AlphaSights deletes your personal information and tells our
service providers to do the same, subject to certain exceptions (such as when we
are legally required to keep the information).

12.3 Right to opt out of selling and sharing
With your consent, we may share your personal information (in the form of your
Usage Data and Technical Data) with third party partners for the purposes of
servicing relevant adverts to you on our behalf (see Section 5.1 for more
information). If you would like to opt-out of sharing your personal information
for the purposes of cross-context behavioural advertising, please update your
cookie preferences by navigating to the “Your Privacy Choices” page on the
website.

12.4 Right to correct
You can request that AlphaSights corrects inaccurate information that we have
about you. For more information see Section 10.1 above.

12.5 Right to limit use and disclosure of your sensitive personal information
You can direct businesses to only use your sensitive personal information for
limited purposes, such as providing you with the services you requested. In the
limited circumstances where we collect your sensitive personal information, we
always limit the use of that information to that which is necessary to provide
you with the goods and services requested. We will not use or disclose your
sensitive personal information for any other purpose.

13. Your rights where you are located in the People's Republic of China


This section supplements and (in the event of conflict only) supersedes the
other sections of this Privacy Policy to the extent you are located in the PRC
when we process your personal information.

Please see the following sections above for information on:

 * The categories of personal information we process (Section 2);
 * The length of time AlphaSights will retain your personal information (Section
   9).

13.1 Why do we process your personal information and under what legal basis can
we do so?
We may collect, record, store, organise, structure, analyse, use, process,
share, update and delete your personal information for the following purposes
and will rely on the follow legal bases under the PIPL to do so:

 * Where we obtain your consent, including:
    * To facilitate engagements between experts and our clients, including
      researching, filtering, verifying, screening and monitoring experts to
      assess and recommend an expert’s appropriateness for a particular client
      engagement and to meet applicable legal, regulatory and compliance
      requirements, including conducting proportionate searches relating to
      bankruptcy, political affiliation and criminal convictions;
    * To record phone calls and meetings between clients and experts at the
      request of clients;
    * To manage our client and user accounts, such as billing, providing client
      support and client relationship management;
    * To place non-essential cookies or similar technologies on your device;
    * On other occasions, for other purposes that we explain at the time.

 * Where it is necessary for the conclusion or performance of a contract to
   which you are a party, including:
    * To conclude and perform our contract with you for the provision of our
      products and services and to send you service-related communications;
    * To manage payments to the extent the processing of Financial Data is
      necessary to compensate our experts.

 * Where it is necessary for the performance of statutory duties or obligations,
   including:
    * In response to requests by government or law enforcement authorities
      conducting an investigation.
    * To comply with applicable reporting, disclosure or other legal
      obligations.

 * Where the personal information has been disclosed publicly, including:
    * Where you make personal information available on public online channels.

 * Where otherwise permitted by applicable law.

With your consent, we may share your personal information, including
transferring it outside of the PRC, with the categories of third parties listed
in Section 6 of this Privacy Policy. When we transfer your personal information
outside of the PRC, we ensure that the recipient of your personal information
has appropriate safeguards in place to protect your personal information.

13.2 What are my rights under the pipl and how can I exercise them?
Under the PIPL, you have the right to:

 * Know and make decisions on the processing of your personal information;
 * Restrict or refuse others from processing your personal information, unless
   otherwise provided for by laws and administrative regulations;
 * Ask us to provide you with access to, or a copy of, your personal information
   in a timely manner;
 * Request that we transfer your personal information to another personal
   information processor designated by you;
 * Request that we make corrections or supplements to your personal information
   in a timely manner if it is inaccurate or incomplete;
 * Request deletion of your personal information in certain circumstances;
 * Request that we explain the rules on the processing of personal information;
 * Unless otherwise arranged by the deceased, request the rights of consulting,
   copying, correcting and deleting of the personal information of a deceased
   relative.

See Section 11 for how to contact us if you would like to make such requests, or
if you have any further questions about your rights and this Privacy Policy.

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